FCC Open Internet Transparency

The US Federal Communications Commission has issued guidance on how ISPs should go about disclosing the performance of their service. (The FCC guidance notes together with my highlights are here.) I have undertaken a quick and informal review of these guidelines to determine if they are fit for purpose.

There are some big caveats:

  • This is not a formal review. There are no documented evaluation criteria and the results are not peer reviewed. The FCC’s staff have not had any opportunity to comment or correct mistakes.
  • I have not followed all the references to the large paper trail of historical and supporting documents. The FCC may have addressed some of my concerns elsewhere.
  • The issues being addressed are systemic ones, so any shortfall by the FCC should be seen in the context of an immature industry, and are a shared industrywide problem.
  • We have not yet seen the European equivalent guidelines, which are due to be issued this coming Monday, so have no benchmark to compare against.

My review has two parts:

  • A technical critique of the stated policy aims, service description and measurement approach.
  • An evaluation against ten criteria that would make for a ‘good’ regulatory framework, together with a summary commentary.

So, is the FCC’s work helpful or hopeless? You will have to decide! The evidence is in my presentation up on SlideShare.

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